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from 1999 to taxes petitioner owed for 1994 and applied only
petitioner’s three estimated tax payments for 2000 totaling
$7,938.87 to petitioner’s 2000 tax liability, respondent
determined that petitioner underpaid his taxes for 2000 by
$3,152.35 ($11,091.22 - $7,938.87). Respondent also assessed a
penalty for underpayment of estimated tax and interest.
The transcript of petitioner’s 2000 taxes shows that on
November 5 and 12, 2001, respondent sent petitioner notices of
balance due for his 2000 taxes. On July 30, 2002, petitioner
filed a petition for bankruptcy under 11 U.S.C chapter 7 seeking
discharge of his tax liabilities for 1992-95. On November 13,
2002, the bankruptcy court granted petitioner a discharge of
those taxes.
On October 14, 2003, respondent issued a Final Notice of
Intent to Levy and Notice of Right to a Hearing with respect to
petitioner’s 2000 tax liability. Petitioner filed a timely
request for a hearing.
On March 24, 2004, Appeals Officer Jacquelyn Sansbury met
with petitioner. Appeals Officer Sansbury had no prior
involvement with regard to petitioner’s tax liabilities. At the
meeting, petitioner asserted the proposed collection of the 2000
taxes was improper because the Internal Revenue Service (IRS)
ignored his direction to apply the 1999 overpayment to his 2000
estimated taxes.
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